Mindspark
Interactive Network, Inc. (“Mindspark”), respects the privacy of
users of our Guffins products, including the Guffins Toolbar
(“Guffins Product”); any related software running on Mindspark
servers and Guffins related services (collectively “Services”),
and has developed this Privacy Policy to demonstrate its commitment
to protecting your privacy. These privacy policies (the “Privacy
Policy”) are intended to describe for you, as an individual who is
a user of the Services, the information we collect, how that
information may be used, with whom it may be shared, and your choices
about such uses and disclosures.

We
encourage you to read this Privacy Policy carefully when using the
Services. By using any of the Services, you are accepting the
practices described in this Privacy Policy. Mindspark Interactive
Network, Inc. is a part of the IAC family of businesses
(www.iac.com),
which includes Ask.com, iWon.com,
Girlsense.com, Citysearch, Vimeo.com, Evite,
Match.com, ServiceMagic, Gifts.com, Pronto,
Shoebuy, College Humor, and many others.

If
you have any questions about our privacy practices, please refer to
the end of this Privacy Policy for information on how to contact us.

Use
of the Guffins Product is governed by Terms of Service which is
available here;
access to portions of the Guffins Product is conditioned on the
download and continued installation of the Guffins downloadable
toolbar application (the “Toolbar”), which is governed by the End
User License Agreement available here.
The information collection practices on the Guffins Product are
governed by this Privacy Policy.

INFORMATION
WE COLLECT ABOUT YOU

In
General.
The Services do not require registration. However, you may be
required to register to use certain aspects of the features available
on or via the Guffins Product. Except
as provided for in the relevant privacy policy(ies), we do not
collect any personally identifiable information (such as names or
email addresses) about you, unless you specifically decide to provide
such information (such as by emailing a help request to us). The
Services may collect the following information:

Information
collected automatically.
We automatically collect information from your browser when you use
the Guffins Product. This
information includes your IP address, your browser type and
language, access times, the content of any undeleted cookies that
your browser previously accepted from us (see “Cookies” below),
and the referring website address.

Cookies.
When you use the Guffins Product, we may assign your computer one
or more cookies,
to facilitate access to our site(s) and to personalize your online
experience. Through the use of a cookie, we also may automatically
collect information about your online activity on our site(s), such
as the web pages you visit, the links you click, and the searches
you conduct on our site(s). Most browsers automatically accept
cookies, but you can usually modify your browser setting to decline
cookies. If you choose to decline
cookies,
please note that you may not be able to use some of the features
offered on or via certain Services.

Other
Technologies.
We may use standard Internet technology, such as web
beacons
and other similar technologies, to track your use of the Guffins
Product. The information we obtain in this manner enables us to
customize the services we offer our users to deliver targeted
advertisements and to measure the overall effectiveness of our
online advertising, content, programming or other activities.

Information
collected by Partners. By
using the Guffins Product, you may have the ability to access
certain sites or features provided by one or more of our third party
partners. The privacy practices relating to any such partners may
be found on their respective websites. We strongly recommend you
take the time to familiarize yourself with these practices prior to
using the relevant site or feature

Information
collected by other third-parties.
We may allow third-parties, including our authorized service
providers, IAC companies, advertising companies and ad networks, to
display advertisements or place ad tags or beacons on our site.
These companies may use tracking technologies, such as cookies,
to collect information about users who view or interact with their
advertisements. This information allows them to deliver targeted
advertisements and gauge their effectiveness. Unless
expressly stated otherwise, the
Services do not provide any personal information to these third
parties Some of these third-party advertising companies may be
advertising networks that are members of the Network Advertising
Initiative, which offers a single location to opt out of ad
targeting from member companies (www.networkadvertising.org).

Social
networking sites.
We may be able to collect information from social networking sites
on which you have registered and used the Guffins Product (in
accordance with the terms of use of those sites). When you use a
Guffins Product on your social networking page or someone else’s
page, we may record information relating to your use of that Guffins
Product. and we may collect information that is visible to the
public from your page, in accordance with the relevant terms of use
of the site. It is your responsibility to read and understand the
terms of use and privacy policy for any social networking site you
choose to use.

HOW
WE USE THE INFORMATION WE COLLECT

In
General.
We may use information that we collect about you to:

deliver
the products and services that you have requested;

manage
your account and provide you with customer support;

perform
research and analysis about your use of, or interest in, our
products, services, or content, or products, services or content
offered by others;

develop
and display content and advertising tailored to your interests on
our site and other sites;

enforce
our terms and conditions;

manage
our business and

perform
functions as otherwise described to you at the time of collection.

Please
review “YOUR
CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION”below.

WITH
WHOM WE SHARE YOUR INFORMATION

We
want you to understand when and with whom we may share personal or
other information we have collected about you or your activities on
our Guffins Product.

Personal
information. We do not share your personal
information with others except as indicated below or when we inform
you and give you an opportunity to opt out of having your personal
information shared. We may share personal information with:

Authorized
service providers: We may share your
personal information with our authorized service providers that
perform certain services on our behalf. These services may include
fulfilling orders, providing customer service and marketing
assistance, performing business and sales analysis, supporting our
website functionality, providing email or electronic message
delivery, and supporting contests, sweepstakes, surveys and other
features offered through our Services.
These service providers may have access to personal information
needed to perform their functions but are not permitted to share or
use such information for any other purposes.

Business
partners: When you use
the Services, we may share personal information with the businesses
with which we partner to offer you those products and/or services.
When you elect to engage in a particular merchant’s offer or
program, you authorize us to provide your email address and other
information to that merchant.

Other
IAC businesses. We are part of the IAC
family of businesses (go to www.iac.com
for a listing of these businesses).
We may share information we collect, including personal
information, with the IAC companies.

Other
Situations. We also may disclose your
information:

In
response to a subpoena or similar investigative demand, a court
order, or a request for cooperation from a law enforcement or
other government agency; to establish or exercise our legal
rights; to defend against legal claims; or as otherwise required
by law. In such cases, we may raise or waive any legal
objection or right available to us, in our
sole discretion.

When
we believe disclosure is appropriate in connection with efforts
to investigate, prevent, or take other action regarding illegal
activity, suspected fraud or other wrongdoing; to protect and
defend the rights, property or safety of our company, our users,
our employees, or others; to comply with applicable law or
cooperate with law enforcement; or to enforce our Website terms
and conditions or other agreements or policies.

In
connection with a substantial corporate transaction, such as the
sale of our business, a divestiture, merger, consolidation, or
asset sale, or in the unlikely event of bankruptcy.

Any
third parties to whom we may disclose personal information may have
their own privacy policies which describe how they use and disclose
personal information. Those policies will govern use, handling and
disclosure of your personal information once we have shared it with
those third parties as described in this Privacy Policy. If you want
to learn more about their privacy practices, we encourage you to
visit the websites of those third parties. These entities or their
servers may be located either inside or outside the United States.

Aggregated
and non-personal information.
We may share aggregated and non-personal information we collect
under any of the above circumstances. We may also share it with
third parties and our IAC sister companies to develop and deliver
targeted advertising on our websites and on websites of third
parties. We may combine non-personal information we collect with
additional non-personal information collected from other sources. We
also may share aggregated information with third parties, including
advisors, advertisers and investors, for the purpose of conducting
general business analysis. For example, we may tell our advertisers
the number of visitors to our Guffins Product and the most popular
features or services accessed. This information does not contain any
personal information and may be used to develop website content and
services that we hope you and other users will find of interest and
to target content and advertising.

THIRD-PARTY
WEBSITES

When
using certain of the Services, you may choose to click on a link to
access other websites that do not operate under this Privacy Policy.
For example, if you click on a news link or advertisement, you may be
taken to a website that we do not control. Or, you may access a
Guffins Product that is hosted by third party website or social
network. These third-party websites may independently solicit and
collect information, including personal information, from you and, in
some instances, provide us with information about your activities on
those websites. We recommend that you consult the privacy statements
of all third-party websites you visit by clicking on the “privacy”
link typically located at the bottom of the webpage you are visiting.

YOUR
CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION

You
can choose not to allow Mindspark to collect certain information,
but that may result in you being unable to use all of the features
of the Guffins Product.

You
may tell us not to share your personal information with third
parties or the IAC family of companies for direct marketing purposes
by clicking on the following link and entering
the email address associated with your account: email us at
info@help.guffins.com.

HOW
WE PROTECT YOUR PERSONAL INFORMATION

We
take appropriate security measures (including physical, electronic
and procedural measures) to help safeguard your information from
unauthorized access and disclosure. For example, only authorized
employees are permitted to access your information, and they may do
so only for permitted business functions. In addition, we use
encryption in the transmission of any personal information between
your system and ours, and we use firewalls to help prevent
unauthorized persons from gaining access to your personal
information.

We
want you to feel confident using our Guffins Product. However, no
system can be completely secure. Therefore, although we take steps
to secure your information, we do not promise, and you should not
expect, that your personal information, searches, or other
communications will always remain secure. Users should also take care
with how they handle and disclose their personal information and
should avoid sending personal information through insecure email.
Please refer to the Federal Trade Commission’s website at
http://www.ftc.gov/bcp/menus/consumer/data.shtm
for information about how to protect yourself against identity theft.

CHILDREN’S
PRIVACY

The
Guffins Products are accessible to the general public, and we do not
knowingly solicit or collect personal information from children under
the age of 13. If you believe we might have collected information
from or about a child under the age of 13, please contact us at
privacy@mindspark.com.

VISITING
OUR WEBSITES FROM OUTSIDE THE UNITED STATES

This
Privacy Policy is intended to cover collection of information via
the Guffins Services from residents of the United States. If you are
using the Services from outside the United States, please be aware
that your information may be transferred to, stored, and processed in
the United States where our servers are located and our central
database is operated. The data protection and other laws of the
United States and other countries might not be as comprehensive as
those in your country. Please be assured that we seek to take
reasonable steps to ensure that your privacy is protected. By using
our services, you understand that your information may be transferred
to our facilities and those third parties with whom we share it as
described in this privacy policy.

NO
RIGHTS OF THIRD PARTIES

This
Privacy Policy does not create rights enforceable by third parties or
require disclosure of any personal information relating to users of
the website.

CHANGES
TO THIS PRIVACY POLICY

We
will occasionally update this Privacy Policy to reflect changes in
our practices and services. When we post changes to this Privacy
Policy, we will revise the “Last
Updated” date at
the top of this Privacy Policy. If we
make any material changes in the way we collect, use, and/or share
your personal information, we will notify you by sending an email
to the email address you most
recently provided us in your account, profile or registration (unless
we do not have such an email address), and/or by prominently posting
notice of the changes on the Guffins homepage and/or fanpage. We
recommend that you check the homepage and/or fanpage from time to
time to inform yourself of any changes in this Privacy Policy or any
of our other policies.

HOW
TO CONTACT US

If
you have any questions about this Privacy Policy or our
information-handling practices, or if you would like to request
information about our disclosure of personal information to third
parties for their direct marketing purposes, please contact us by
email
or postal mail as follows:

A
cookie is a small text file that is stored on a user′s
computer for record keeping purposes. Cookies can be either session
cookies or persistent cookies. A session cookie expires when you
close your browser and is used to make it easier for you to navigate
our website. A persistent cookie remains on your hard drive for an
extended period of time.

Through
the use of a cookie, we also may automatically collect information
about your online activity on our site, such as the web pages you
visit, the links you click, and the searches you conduct on our site.
When you sign in to your account on our website, we will record your
user or member ID and the name on your user or member account in the
cookie file on your computer. We also may record your password in
this cookie file, if you indicated that you would like your password
saved for automatic sign-in. For security purposes, we will encrypt
any usernames, passwords, and other user or member account-related
data that we store in such cookies. In the case of sites and services
that do not use a user or member ID, the cookie will contain a unique
identifier. We may allow our authorized service providers to serve
cookies from our website to allow them to assist us in various
activities, such as doing analysis and research on the effectiveness
of our site, content and advertising.

You
may delete or decline cookies by changing your browser settings.
(Click “Help” in the toolbar of most browsers for instructions.)
If you do so, some of the features and services of our website may
not function properly.

We
may allow third-parties, including IAC companies, advertising
companies, and ad networks, to display advertisements on our site.
These companies may use tracking technologies, such as cookies, to
collect information about users who view or interact with their
advertisements. Our website does not provide any personal information
to these third parties, but they may collect information about where
you, or others who are using your computer, saw and/or clicked on the
advertisements they deliver, and possibly associate this information
with your subsequent visits to the advertised websites. They also may
combine this information with personal information they collect from
you. The collection and use of that information is subject to the
third-party′s
privacy policy. This information allows them to deliver targeted
advertisements and gauge their effectiveness. Some of these
third-party advertising companies may be advertising networks that
are members of the Network Advertising Initiative, which offers a
single location to opt out of ad targeting from member companies
(www.networkadvertising.org).

Web
Beacons:

Web
beacons (also known as clear gifs, pixel tags or web bugs) are tiny
graphics with a unique identifier, similar in function to cookies,
and are used to track the online movements of web users or to access
cookies. Unlike cookies which are stored on the user′s
computer hard drive, web beacons are embedded invisibly on the web
pages (or in email) and are about the size of the period at the end
of this sentence.

Web
beacons may be used to deliver or communicate with cookies, to count
users who have visited certain pages and to understand usage
patterns. We also may include web beacons in promotional [or other]
e-mail messages or newsletters to determine whether messages have
been opened and acted upon. We also may receive an anonymous
identification number if you come to our site from an online
advertisement displayed on a third-party website.